On December 18, GOTS posted an updated version of the Manual for Implementation. This document should be reviewed along with the Standard to understand the implementation of GOTS 7.0. 

The new version should replace any versions you may have downloaded as part of your recordkeeping requirements from the GOTS website.

A Change Log was also provided corresponding with the Manual for Implementation and can be downloaded and reviewed from the GOTS website.

Changes to the Manual for Implementation include updated guidance regarding the newly released Due Diligence Handbook for Certified Entities, updates to language regarding PFAS, workers’ rights for freedom of movement, and the anonymous complaint mechanism, among other updates. Please download, add the documents to your files, and review for necessary changes to your operation.

Time marches on toward the March 1, 2024 Implementation Date for GOTS 7.0!  By this time all Certified Entities should have downloaded the new standard and started making necessary changes to systems to meet the updated Standard. It is expected that the changes to your systems will be implemented by March 1, 2024. 

OTCO staff has sent out several updates and blog posts to provide up-to-date information about these new requirements. Please see below for details on required paperwork submissions.

As mentioned in our notification and GOTS Blog we posted on November 23, 2023, OTCO has updated all GOTS Organic System Plan (OSP) Modules (FT documents) and Worksheets as required to implement GOTS Version 7.0.

For existing OTCO clients, our team developed a new form that captures all of the 7.0 OSP updates so you do not need to complete each updated module. The OSP Update Form for GOTS 7.0 is available for download from this link to our forms webpage.

Per the 7.0 Standard and Manual for Implementation, the Due Diligence Management Process requirement is a “shall” (meaning mandatory). OTCO developed the FT10 -Due Diligence Management Process module to guide clients in how to document that your operation meets this new process requirement.

All OTCO clients must review and complete this document to both support your implementation of this requirement and show OTCO how you will be complying. Please dedicate time to understanding and implementing these new requirements.

The implementation status of Due Diligence and completion of necessary forms will be verified at your next annual inspection. You may submit these forms anytime to fibertextile@tilth.org, but they must be submitted before or during your next inspection.

To support our clients, OTCO’s Fiber & Textiles Team is presenting a webinar called “How to Right Size Due Diligence Management Process for your Company.” Please be sure to invite anyone within your organization to join us at Noon (Pacific) on Thursday, February 29, 2024. Attendance is not mandatory, but this training will give you a clearer understanding of how to approach the new requirement and the presentation will be recorded.

This webinar will explore how to approach this new requirement. GOTS 7.0 has included a new requirement for a Due Diligence Management Process as part of the implemented Social, Environmental, and Governance criteria that has been part of the standard for the past 4 iterations. To meet the guidelines for the OECD Due Diligence Guidance for Responsible Supply Chains in the Garment and Footwear Sector, GOTS has laid out a six-step framework for the Due Diligence process. This webinar will review these steps and offer ideas and working queries to support the development of this important and required process for all our Certified Entities, regardless of size.

Working Time at Gins and New GOTS Advisory! 

Over the past four years, OTCO has been under pressure to enforce the GOTS Standard regarding working time at gins, as implemented under GOTS v5.0. With each change to the Standard, the working time requirements have been tightened. We have heard the challenges at the gin level and worked with our operators to move toward compliance. 

Just as OTCO audits your operations, OTCO is audited annually by an oversight body, IOAS. Last year we received a Noncompliance regarding Working Time at gins from IOAS for not applying the GOTS v6.0 Standard appropriately and allowing continued seasonal overtime at gins. 

Understanding that the gins would not be able to continue to operate and be certified to GOTS under such restrictions, OTCO reached out to GOTS. We were able to supply extensive background information, including US Regulations that support both our gins and their employees. With this submission of information and our request for assistance, we ensured that GOTS understood the need for Ginning to be assessed as agricultural post-harvest work. The Social Criteria portion of the GOTS Standard is based on the International Labour Organization (ILO) Criteria, which does not have different working hours for agricultural work. The response from GOTS was very positive and it was clear that this was an issue that affects gins across the globe. We received a rather quick response from GOTS with a draft advisory on the subject of working time. OTCO provided feedback to GOTS, and it is clear they listened to their certifiers across the globe to develop the attached GOTS Advisory for Assessment of Working Hours for GOTS Certified Cotton Ginners which was delivered to GOTS Certifiers on Feb 6, 2024. We are grateful to the OTCO Gins who helped provide feedback on this issue and for your cooperation throughout the past season.

Gin inspection reports for the 2023 season have either been reviewed and completed or are in work. Before this advisory was released, OTCO issued Noncompliances to those that were not meeting the Standard as written. We will work with the gins to resolve issued Noncompliances, and we will issue reminders that will include the details of the Advisory in each certification decision letter, along with a copy of the Advisory. Once GOTS releases this information on their website, we will post a link on our website to ensure easy access to the information. 

GOTS requires that all incoming lots of raw organic cotton be sampled from incoming cotton prior to ginning and tested for the presence of GMOs at an approved lab testing to the ISO IWA 32:2019 protocol. The qualitative results of said tests are required to be submitted to OTCO for review. Additionally, each gin is required to annually submit an updated Master Ingredient List (MIL) including all your cotton producers and other required information, along with the producer’s current NOP organic certificates. GOTS and OTCO require these items to be submitted for review before any sales or issuance of Transaction Certificates. As such, this information is overdue if you have not yet sent it our way. We aim to have results reviewed and approved by the end of March 2024, but to meet that goal we must receive your information right away. 

Please note: GMO Tests are only valid for Transaction Certificates after we’ve received, reviewed, and stamped the test result. If your GMO Test Result has quantitative percentages listed, you must request an updated version of the test from your lab that lists “detect” vs “non-detect” only.

GOTS does not require your 2023 organic cotton crops to be tested for pesticide residues. However, it will be required for the 2024 ginning season later this year. OTCO is working with organic cotton farmers and Extension Agents to pin down appropriate pesticide compounds to meet GOTS requirements and ensure that the testing performed is applicable to the organic cotton grown in the US. We will continue to keep you informed about this requirement. 

If any GINS or growers are interested in participating, reach out to Bob Whitney at: bob.whitney@ag.tamu.edu

As ginning season is closing out and gin business turns to moving the cotton and requesting Transaction Certificates, please remember each operation MUST  update your Inventory Spreadsheet so that our Transaction Services Team has volume to draw from. OTCO is required to verify the availability and production numbers before issuing Transaction Certificates. 

Please keep in mind that this amount should be ALL of the Organic Cotton you have processed for the year, not just what has been sold or claimed or otherwise. Inventory numbers must represent total organic production.